Commercial Banking: Robust business model providing attractive returns ING Investor Day William Connelly CEO Commercial Banking Amsterdam 13 January 2012
ING Commercial Banking: Robust business model providing attractive returns 1 Commercial Banking showed strong performance through the crisis by allocating capital to core markets and high-return businesses Annerie Vreugdenhil Case study Corporate Clients Netherlands 2 External and regulatory challenges will lead to some strategic adaptations, particularly in Financial Markets Percy Rueber - Case study Financial Markets 3 4 As part of the balance sheet integration initiatives, Structured Finance will grow its high yielding assets Christopher Steane - Case study Structured Finance Overall Commercial Banking strategy stable, building upon our unique strengths ING Investor Day - 13 January 2012 2
Commercial Banking has performed strongly throughout the crisis and continues to perform well Underlying income* (EUR mln) 4,188 5,350 4,657 4,059 3,777 191 3,857 2007 2008 2009 2010 9M10 9M11 Impairments on Greek government bonds Risk costs* 72 34 33 38 31 594 1,207 490 422 316-144 2007 2008 2009 2010 9M10 9M11 Risk costs (EUR mln) Risk costs (bps**) Underlying result before tax* (EUR mln) Commercial Banking has performed strongly throughout the crisis and continues 2,217 1,856 to perform well 1,648 191 Risk costs remained under control 1,042 752 1,643 The result in 2008/2009 was negatively impacted by FV changes and impairments on Real Estate investments and 2007 2008 2009 2010 9M10 9M11 development projects but real estate Impairments on Greek government bonds exposure has since been reduced sharply Adjusted for sale of Car Lease and REIM **As percentage of average RWA ING Investor Day - 13 January 2012 3
Strict cost discipline resulted in efficiency which is among the best in the industry Cost / Income ratio* 64% 59% 52% 49% 49% 46.9% Cost / Income ratio CIB activities*, ** (9M11) 93% 86% 71% 69% 65% 56% 49% 38% 2007 2008 2009 2010 9M11 C/I ratio Excl. Impairments on Greek government bonds UBS CS DB Bar SG BNPP ING San Headcount has been reduced by 10% since 2008* Limited and targeted new hires to re-balance capabilities Cost/income ratio first nine months of 2011 impacted by impairments on Greek government bonds * Adjusted for divestments (sale of Car Lease and REIM) ** CIB activities refers to Investment Banking (UBS, CS), Corporate & Investment Banking (DB, Barclays, SocGen, BNPP), Commercial Banking (ING) and Global Wholesale Banking (Santander) ING Investor Day - 13 January 2012 4
Capital has been allocated to higher return businesses, SF in particular, and ROE has increased RWA (EUR bln) 174.2 156.6 140.2 135.5 2008 2009 2010 9M11 RWA per product (EUR bln) RoE* 9M 2011 by product (%) 38.3% 28.7% 25.4% 19.1% 29.3% 22.0% 18.2% 13.6% 11.4% 8.6% 9.6% 7.2% REF SF FM L&F GL & PCM RoE at CT 1 ratio of 7.5% RoE at CT 1 ratio of 10% Impairments on Greek government bonds RoE* (%) 18 9 41 41 43 33 9 6 57 REF SF FM L&F GL&PCM 2008 3Q11 39 4.5% 7.0% 3.4% 5.3% 15.4% 11.6% 18.2% 16.5% 13.7% 12.4% 2008 2009 2010 9M11 RoE at CT 1 ratio of 7.5% RoE at CT 1 ratio of 10% Impairments on Greek government bonds * Return on Equity = Underlying after-tax return divided by equity based on average 7.5% core Tier 1 ratio (annualised) ING Investor Day - 13 January 2012 5
Commercial Banking has strong regional positions and world-class franchises ING is the leading Commercial Bank in the Benelux Voted Best Bank in the Netherlands (The Banker, 2011) Voted Best M&A Financial Advisor in the Benelux (FT Merger Market, 2011) Recognised as preferred advisor by clients (Greenwich Survey, 2011) Extensive and unique regional network in Europe, especially in CEE Superior global network, especially in CEE, supporting our Benelux client base. Recognised as most preferred bank for business in CEE by our clients (Greenwich / Client surveys) Superior network, supporting our global product franchise Facilitating an attractive franchise servicing multinationals (esp. from US and Western Europe, and particularly their operations in Benelux/CEE) ING has strong global franchises in Specialised Finance and Financial Markets Leading Specialised Finance franchise (#10 MLA, Thomson Reuters/Dealogic, 2007-2011) Best global commodity finance bank (Global Trade Review, 2011) Strengthening foothold in European DCM, reflected by #8 position in Euro Investment Grade Corporate Bonds (Thomson Reuters, 3Q11) Top 3 position in FM in the Benelux corporate market and Top 5 positions in chosen global emerging market niches ING Investor Day - 13 January 2012 6
Case study: Corporate Clients Netherlands Annerie Vreugdenhil, Head of Commercial Banking NL ING Investor Day - 13 January 2012 7
Full-service Commercial Banking in the Netherlands, supporting client needs from payments through to strategic advice Income Commercial Banking CC NL (EUR mln)*, ** 418 458 CAGR 8.9% 546 564 587 2007 2008 2009 2010 2011 estimate Commercial Banking CC NL has a ROE of 20% in 9M11*** *CC NL is Corporate Clients Netherlands; ** Excl. capital gains and impairments; ***R0E based on 7.5% core Tier 1 ratio (annualised, RoE based on core Tier 1 ratio of 10% is 15%) Number 1 Commercial Bank in the Netherlands Full-service Commercial Banking in the Netherlands ING has improved its market position in the Netherlands and is now the leading financial institution Leading position has resulted in improved results without allocating more capital We are well positioned for further growth through increasing cross-selling and improving capabilities and market share in certain products Our successes in the Dutch LargeCorp market can be translated to the MidCorp market and other countries ING Investor Day - 13 January 2012 8
ING has improved its market position in the Netherlands and is now the leading Commercial Bank ING is the leading Commercial Bank in the Netherlands The change of competitive landscape in the Netherlands in 2007/2009 led to a window of opportunity ING took the opportunity to step up and take leadership. We continued to focus on our service offering and have selectively invested in our product capabilities, particularly ECM, DCM and M&A. This established the basis for our current success We remain well positioned for further growth as we continue to selectively invest in certain products, PCM in particular, and our network offering Preliminary 2011 numbers from Greenwich indicates that ING is the leading Commercial Bank in the Netherlands for the 3rd consecutive year ING is the number 1 Commercial Bank in the Netherlands 93 88 66 2006 2010 2 1 80 70 35 63 56 19 ABN ING Rabo Total relationships Lead relationships Source: Greenwich Survey 81 76 44 75 68 34 72 66 45 ING Rabo RBS Core relationships ING Investor Day - 13 January 2012 9
The strengths of our Commercial Bank in the Netherlands are also reflected in strong product capabilities Leadership position in the Netherlands also reflected in high league table rankings for our core products MLA Syndicated Loans - from # 2 in 2007 to # 1 in 2011 (value and amount of transactions)* Market Penetration Cash Management from # 3 in 2007 to # 2 in 2010** M&A from # 17 in 2007 to # 1 in 2011 (value of transactions)* DCM corp from # 13 in 2007 to # 4 in 2011 (value of transactions)* ECM - from # 9 in 2007 to # 1 in 2010 (amount of transactions)* Awards showing our leadership position ING voted Best M&A Advisor in the Benelux (FT Merger Market, 2011) ING wins Best Trade Finance Bank award (Global Finance magazine) * Thomson Reuters ** Greenwich ING Investor Day - 13 January 2012 10
ING Commercial Banking is the only Dutch bank with a large international network, spanning 40 countries ING Home Markets ING Commercial Banking presence Alliance Banking (with SEB) ING will further leverage its network for increased international flows ING Investor Day - 13 January 2012 11
Strategy CC NL going forward is aimed at further strengthening of leadership positions and attractive returns Further strengthen leadership position Improve returns without allocating more capital Increase funding Further strengthening of leadership position as foreign players retrench Continue to invest and grow market share in product capabilities, particularly in: Payments and Cash Management Supply Chain Finance / Working Capital Solutions Trade Finance Selective hiring to further improve client relationship management Exploit leadership position, further increasing cross- and deep-sell Leverage network for increased international flows Continuously improve efficiency of capital allocation by prioritisation of clients Re-price to absorb higher funding costs and optimise portfolio Targeted campaigning to increase customer deposits Strong focus on increasing market share in PCM ING Investor Day - 13 January 2012 12
Our successes in the Dutch Large-Corp market can be translated in the Mid-Corp market and other countries NL 430 relations 40.000 relations NL Belgium Germany Poland Large- Corp Mid-Corp Strategic Products Fully tailored to company needs Event Finance, ECM, DCM, Corp Finance Transaction Based Products Tailored solutions with modular products P&CM, Lending, FM, Lease, Com.Fin, Event Finance, Corp. Finance 550.000 relations SME Standardised products Lending, Lease PCM Our successes in the Dutch Large-Corp market can be copied to other home markets. Translate our successes in the Large-Corp market to the Mid-Corp and SME markets ING Investor Day - 13 January 2012 13
Impact of new regulation and strategic adaptations William Connelly, CEO Commercial Banking ING Investor Day - 13 January 2012 14
Regulatory changes will put pressure on returns, particularly in the Financial Markets business RWA Commercial Banking (EUR bln) 15-14 11 RoE and pro-forma RoE Basel 3, after identified management actions, 9M11*** 18.2% 12.5% > 13% 136 148 11.4% 9M11 Basel 2.5 Basel 3* Identified mgt actions** 38.3% 28.7% 29.3% 22.0% 25.4% 12.5% 11.4% 10.1% 9.6% 7.2% 10.3% 8.6% REF SF FM*** L&F GL & PCM Basel 2 and based on CT1 ratio of 7.5% Identified management actions Pro-forma Basel 2, based on CT 1 of 7.5% Pro-forma Basel 2.5/3, based on CT 1 of 10%, after mgt actions** Target 2015 Identified management actions RoE* and pro-forma RoE Basel 3 by product, after identified management actions, 9M11* Basel 2.5/3 and based on CT1 ratio of 10%, after mgt actions * Basel 3 impact is initial, indicative estimate that is still subject to change ** RWA impact of management actions refer to FM (EUR -10 bln), RED / RE Investments (EUR -3 bln) and General Lease (EUR -1 bln) *** RoE adjusted for impairments on Greek government bonds ING Investor Day - 13 January 2012 15
ING has been responding by (re-)positioning its product offering Lease Real Estate Investments & Development Lending PCM Lease activities in non-core markets are under review (EUR 5 bln of RWA) Several countries placed in run-off leading to a net RWA reduction of at least EUR 1 bln Reduce exposure to Real Estate Investments and Real Estate Development projects (EUR 3 bln RWA) Eventual exit in 2015 Accelerating balance sheet optimisation initiatives across regions Re-allocating resources towards core franchises and clients Maintaining strict pricing discipline and maximising cross sell managing for returns Investments in trade and flow products (fee generating, low capital intensity) Supporting core Benelux franchise and network capabilities Supporting deposit gathering abilities Investing circa EUR 80 mln over next 4 years But most significant impact of new regulations is on our Financial Markets platform ING Investor Day - 13 January 2012 16
Case study: Financial Markets Percy Rueber, Global Co-Head Financial Markets ING Investor Day - 13 January 2012 17
Impact of Basel 2.5 and 3 will be partly offset by management actions RWA Financial Markets (EUR bln) Basel 2.5 impact RWA ING and Peers*** 15-10 37% 11 25% 33 49 16% 10% 6% 6% 4% 2% 9M2011 Basel 2.5 Basel 3* Identified mgt actions RoE Financial Markets, 9M11** 25.4% Basel 2, based on CT1 of 7.5% 12.5% 10.3% Pro-forma Basel 2.5/3, based on CT 1 of 10%, after mgt actions Identified management actions Pro-forma > 13.0% Target 2015 UBS DB CS SG Bar BNPP ING San The 2011 year-end implementation of market risk model updates, including the impact of Basel 2.5, is estimated at around EUR 11 bln Indicative, initial RWA impact of Basel 3 is EUR 15 bln Currently identified management actions will lead to a RWA reduction of EUR 10 bln Additional management actions will lead to a further mitigation * Basel 3 is initial, indicative estimate that is still subject to change ** Adjusted for impact of Greek government bonds *** Basel 2.5 RWA divided by Group RWA ING Investor Day - 13 January 2012 18
Identified management actions leading to a EUR 10 bln reduction in RWA Adaptation of Financial Markets platform and de-risking Other measures Restructuring New York platform De-risking of Emerging Markets Credit Trading activities Alignment equities capabilities (secondary, primary, derivatives, financing) in a single Platform Optimise client facilitation model, reduce trade inventories Restructuring Mexico branch Increase collateralised business with corporates and central counterparty clearing Central counterparty exposure management Hedging/portfolio optimisation ING Investor Day - 13 January 2012 19
Financial Markets: Key activities Key activities Hedging solutions to mitigate financial risks for Corporates, companies listed on the stock exchange as well as Institutional clients and Mid-sized corporates Investment solutions to Institutional clients such as pension funds and insurance companies Financing solutions for both Institutional and Corporate clients through the DCM platform Managing the ING Bank balance sheet through the ALCO and Treasury department, in close cooperation with Capital Management. Identifying Strategic Trading positions through the Strategic Trading Platform FM business line Clients & Products ALCO & STP Single Bank treasury to be created over the course of 2012 ALCO/Treasury will be carved out of Financial Markets and reported under 'Commercial Bank Other from 1Q2012 One Bank Treasury ING Investor Day - 13 January 2012 20
Financial Markets: Diversified portfolio FM Income by Geography, 9M11* FM Income by product, 9M11* FM Income by Client Segment, 9M11* 36% 24% 6% 21% 31% 64% Developed markets Emerging markets 6% 2% Rates & FX Credit Trading DCM 62% Global equity Products Corporate Finance 48% Corporate Clients Financial Institutions Product Clients FM is a well diversified business, exposed to developed markets and faster growing economies FM is skewed to rates and FX, rather than credit * Based on new reporting structure (as of 1Q12) ING Investor Day - 13 January 2012 21
Strategy of Financial Markets going forward in a Basel 3 world Further strengthen leadership position Improve returns Other Continue to invest and grow market share in areas of strength such as Debt Capital Markets and Interest Rates in the "Home Markets Capitalise on leadership position in the "International Markets" in strategic locations such as CEE and Asia Align other locations to strategic priorities including risk reduction in the Mexico branch and streamlining product portfolio and the shift to client facilitation in the NY office Enhance product portfolio by introducing an integrated Equities product that aligns our primary, secondary, derivatives and financing capabilities into one client platform Making client-driven business the focus of all products and reducing trading inventories and risk positions accordingly Placing wherever possible the emphasis on collateralised and centrally cleared products Repricing products in line with the markets Prioritise clients and focus on cross-sell in line with Commercial Bank objectives Continue upgrades in operational platforms - completing the FM TOM* and integrating the Equities businesses * Target Operating Model (TOM) ING Investor Day - 13 January 2012 22
Commercial Banking and balance sheet optimisation William Connelly, CEO Commercial Banking ING Investor Day - 13 January 2012 23
Commercial Banking is making a strong contribution to ING Bank s balance sheet optimisation Continue strong deposit growth Replace low-yielding assets with customer lending Balance sheet integration Commercial Banking will focus on gathering liabilities to support the funding and liquidity restrictions in the Dutch NV Clear targets for commercial sales force Targeting deposits with high liquidity value Sell/reduce non-core assets Reduce non-strategic trading assets in Financial Markets to make room for growth in customer lending Evolve customer loan book towards higher-return businesses such as Structured Finance while maintaining a prudent risk/return profile Re-price lending to reflect the higher cost of capital Structured Finance will grow its lending assets in the funding rich entities (Direct and Belgium) as a result of balance sheet integration initiatives to provide them high-yielding assets ING Investor Day - 13 January 2012 24
Increased focus on deposits growth Increased focus on deposits growth will result in a strong growth of funds entrusted Individual targets have been set throughout the organisation and development of funds entrusted is monitored on a weekly basis Initiatives are underway to focus on liquid clients such as non-bank FIs (pension funds etc.) in particular Clients to which we commit our balance sheet and with which we have significant relationships are encouraged to put deposits for longer periods with ING Investments in Payments and Cash Management capabilities will in the medium term further enhance its competitive position in attracting funds Evidence of clients recognising of our improved transaction services is the recently won PCM mandate with the Flemish government Funds Entrusted 2011 - EUR 64 bln 8% 18% 53% 21% NL BeLux RoE RoW ING Investor Day - 13 January 2012 25
In the One Bank organisation, ING is matching high-quality and high-return asset origination with liability-generating capabilities ING Bank s funding position 1st wave: internal securitisations 2nd wave: mortgages 3rd wave: CB assets 4th wave: domestic banks Funding gap in the Netherlands can be reduced through more efficient balance sheet management Units with excess funding invest in internally ringfenced and packaged mortgages Transfer own-originated mortgages directly to funding-rich units Transfer selected Commercial Banking assets to funding-rich units In selected ING Direct countries, merge ING and CB activities into one legal entity ING Belgium and ING Direct are funding rich Transactions completed so far (SF/REF) totalling EUR 3 bln Transactions identified for 2012 (subject to regulatory approval) amount to EUR 5 bln Germany as most advanced example, full merger into one legal entity Structured Finance to establish front office teams in Germany and Belgium to take participations in new and existing SF transactions ING Investor Day - 13 January 2012 26
Case study: Structured Finance Christopher Steane, Global Head of Lending Services ING Investor Day - 13 January 2012 27
Structured Finance Structured Finance business lines Energy, Transport and Infrastructure Group: Natural Resources Utilities-Power Infrastructure Asset-Based Finance Structured Metals & Energy Finance Specialised Financing Group: Telecom and Media Finance Structured Acquisition Finance Structured Securitised Finance / Structured Solutions Group Local Structured Finance (Americas, Asia, UK, CEE, CWE, NL) International Trade and Export Finance: Trade and Commodity Finance Structured Export Finance Trade Finance Services Natural Resources Offshore FI-metrix Commodity Client Survey ING Investor Day - 13 January 2012 28
Structured Finance portfolio is well diversified both geographically and by sector SF lending by sector EUR 52 bln in 9M11 SF lending by country of risk EUR 52 bln in 9M11 12% 0% USA 8.5 NL 3.6 37% UK 3.5 21% China 3.4 Energy, Transport & Infrastructure Specialised Financing Group International Trade & Export Finance 30% Trade Finance Services Other SF lending by region of booking EUR 52 bln in 9M11 12% 30% Russia Switzerland Singapore France Korea Next 10 countries 1.9 1.6 1.3 3.1 2.7 9.5 17% NL* BeLux CWE Asia Americas UK Other 21% 4% * Including non-dutch CB activities booked in the Netherlands 11% 5% Next 10 countries Other countries 5.6 6.9 0 2 4 6 8 10 ING Investor Day - 13 January 2012 29
Structured Finance benefitted from repricing of the portfolio and higher deal flow Structured Finance income (EUR mln) 345 244 179 233 382 713 943 1,095 805 834 2008 2009 2010 9M10 9M11 Interest Income Non-interest income Structured Finance run-off (net) lending assets (EUR bln) 60 40 52 27 20 0 7 2 1 2011 2015 2020 2025 2030 Structured Finance- (net) lending assets (EUR bln) 45 50 52 43 2008 2009 2010 9M11 Mix of: Short-term (Commodity Finance, Trade Finance) Medium term (Telecom, Offshore) Longer-term (Infrastructure) When future lending assets run-off, it will create further repricing opportunities ING Investor Day - 13 January 2012 30
Structured Finance is an efficient business with well controlled risk costs and a high ROE Underlying cost/income ratio (%) 50% 40% 37.3% 30% 25.8% 25.7% 24.2% 20% 10% FY 08 FY09 FY10 9M11 RoE (YTD, %) Underlying risk costs in bps of average RWA 200 150 100 50 0-50 -100 74 147 normalised 40-45 bps -66-1 -17-16 1 128 71 32 14 2001 2003 2005 2007 2009 9M11 9.7% 7.3% 7.3% 5.5% 29.3% 24.2% 21.3% 22.0% 18.1% 16.0% FY08 FY09 FY10 9M10 9M11 Equity based on CT1 of 7.5% Equity based on CT 1 of 10% ING Investor Day - 13 January 2012 31
Repricing yet to be fully realised but accelerating Since the summer loan pricing has begun moving upwards as Banks seek to address capital and funding costs Illustrative return (bps) A-rated Investment Grade Corporate Facilities Drawn Margin Mid 2010 Mid 2011 End 2011 90 70 90 Project Finance 120 175 190 LBO (TLA/RCF) 415 400 435 Offshore 250 230 285 REF 65% LTV on Prime Property 225 225 260 Loan margins fell from June 2010 to June 2011 High level of refinancing activity in H1 2011 Since June 2011, Syndicated Loan markets have shrunk and pricing has begun to rise We think this will continue: currently very cautious approach to underwriting As European banks shrink they will exit some international activities Supply / demand balance will change as continued BRIC growth needs finance On corporate deals: Utilisation fees on first drawing (i.e. >zero) are emerging as opposed to the traditional >33% Utilisation fees have risen from 15/30 bps to 30/50 bps Premiums up to 50bps for US$ facilities have emerged together with restrictions on US$ drawings Tenors did not go beyond 5+1+1 in the recent past and this has now been pulled back to 5 years ING Investor Day - 13 January 2012 32
Commercial Banking strategy going forward William Connelly, CEO Commercial Banking ING Investor Day - 13 January 2012 33
Change in external Commercial Banking reporting structure as of the first quarter 2012 Commercial Banking General Lending and Transaction Services Industry Lending Financial Markets Clients & Products Real Estate, Bank Treasury & Other Corporate & Financial Institutions Lending Payments & Cash Management Bank Mendes Gans General Lease (core) Trade Finance Services Securities Services Structured Finance Real Estate Finance Corporate Investments Clients & Products* Strategic Trading Real Estate Development Real Estate Investment Portfolio ALCO Treasury General Lease (run-off) Commercial Finance Income (9M11) EUR 1,115 mln Income (9M11) EUR 1,553 mln Income (9M11) EUR 920 mln Income (9M11) EUR 268 mln * Including Global Equity Products & Corporate Finance ING Investor Day - 13 January 2012 34
Overall strategy of ING Commercial Banking will remain stable, building upon our strengths Income Commercial Banking, 9M11* 22% 24% NL** Belgium/ Luxembourg Germany CEE Rest of Europe Outside Europe 13% 2% 26% 13% * Income adjusted for Greek impairments booked in Belgium ** Including non-dutch CB activities booked in the Netherlands Going forward, we will: Maintain leadership positions in core markets Benelux & CEE Germany opportunity to develop as core market franchise Maintain leadership in core products Top 10 player in Structured Finance globally Top 3 FM player in the Benelux corporate market Increase focus on cross-selling Capital will continue to be managed prudently and be allocated to core markets and high return businesses with attractive risk / reward characteristics Continue to optimise our cost structure Leading to a sustainable ROE for the Commercial Bank of at least 13% ING Investor Day - 13 January 2012 35
Disclaimer ING Group s Annual Accounts are prepared in accordance with International Financial Reporting Standards as adopted by the European Union ( IFRS-EU ). In preparing the financial information in this document, the same accounting principles are applied as in the 3Q2011 ING Group Interim Accounts. All figures in this document are unaudited. Small differences are possible in the tables due to rounding. Certain of the statements contained herein are not historical facts, including, without limitation, certain statements made of future expectations and other forward-looking statements that are based on management s current views and assumptions and involve known and unknown risks and uncertainties that could cause actual results, performance or events to differ materially from those expressed or implied in such statements. Actual results, performance or events may differ materially from those in such statements due to, without limitation: (1) changes in general economic conditions, in particular economic conditions in ING s core markets, (2) changes in performance of financial markets, including developing markets, (3) the implementation of ING s restructuring plan to separate banking and insurance operations, (4) changes in the availability of, and costs associated with, sources of liquidity such as interbank funding, as well as conditions in the credit markets generally, including changes in borrower and counterparty creditworthiness, (5) the frequency and severity of insured loss events, (6) changes affecting mortality and morbidity levels and trends, (7) changes affecting persistency levels, (8) changes affecting interest rate levels, (9) changes affecting currency exchange rates, (10) changes in general competitive factors, (11) changes in laws and regulations, (12) changes in the policies of governments and/or regulatory authorities, (13) conclusions with regard to purchase accounting assumptions and methodologies, (14) changes in ownership that could affect the future availability to us of net operating loss, net capital and built-in loss carry forwards, and (15) ING s ability to achieve projected operational synergies. ING assumes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information or for any other reason. This document, and any other document or presentation to which it refers, do not constitute an offer to sell, or a solicitation of an offer to buy, any securities. www.ing.com ING Investor Day - 13 January 2012 36